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Author: Georg Friedrich Martens
Publisher:
ISBN:
Category : Europe
Languages : de
Pages : 678
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Author: Georg Friedrich Martens
Publisher:
ISBN:
Category : Europe
Languages : de
Pages : 678
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Author: Per Stenström
Publisher: Springer
ISBN: 3642194486
Category : Computers
Languages : en
Pages : 299
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Transactions on HiPEAC aims at the timely dissemination of research contributions in computer architecture and compilation methods for high-performance embedded computer systems. Recognizing the convergence of embedded and general-purpose computer systems, this journal publishes original research on systems targeted at specific computing tasks as well as systems with broad application bases. The scope of the journal therefore covers all aspects of computer architecture, code generation and compiler optimization methods of interest to researchers and practitioners designing future embedded systems. This third issue contains 14 papers carefully reviewed and selected out of numerous submissions and is divided into four sections. The first section contains the top four papers from the Third International Conference on High-Performance Embedded Architectures and Compilers, HiPEAC 2008, held in Göteborg, Sweden, in January 2008. The second section consists of four papers from the 8th MEDEA Workshop held in conjunction with PACT 2007 in Brasov, Romania, in September 2007. The third section contains two regular papers and the fourth section provides a snapshot from the First Workshop on Programmability Issues for Multicore Computers, MULTIPROG, held in conjunction with HiPEAC 2008.
Author:
Publisher:
ISBN:
Category : Economic assistance, American
Languages : en
Pages : 892
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Author: Zhigeng Pan
Publisher: Springer
ISBN: 3642290507
Category : Computers
Languages : en
Pages : 284
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This journal subline serves as a forum for stimulating and disseminating innovative research ideas, theories, emerging technologies, empirical investigations, state-of-the-art methods, and tools in all different genres of edutainment, such as game-based learning and serious games, interactive storytelling, virtual learning environments, VR-based education, and related fields. It covers aspects from educational and game theories, human-computer interaction, computer graphics, artificial intelligence, and systems design. The 27 papers of this volume deal with virtual humans; graphics rendering and 3D animation; games and 2D animation; and digital media and its applications.
Author: United States. Securities and Exchange Commission
Publisher:
ISBN:
Category : Securities
Languages : en
Pages : 546
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Author:
Publisher:
ISBN:
Category : Securities
Languages : en
Pages : 166
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Author: Geological Society of London. Library
Publisher:
ISBN:
Category : Geology
Languages : en
Pages : 576
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Author:
Publisher:
ISBN:
Category : Insects
Languages : en
Pages : 370
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Author: Government Publications Office
Publisher: Government Printing Office
ISBN: 9780160926464
Category :
Languages : en
Pages : 608
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Volume of the United States Tax Court Reports containing case abstracts and opinions of the court regarding cases between July 1, 2013 December 31, 2013. Cases in each volume are listed in the prefatory table. The United States Tax Court is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 providing (in part) that Congress has the power to "constitute Tribunals inferior to the Supreme Court. “The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment rule”).” Contents 8 Findings of Fact 8 Background 8 John Hancock’s History9 Investment Process and Review10 Leasing10 LILO and SILO Transactions 10 Basic Structure 15 History 17 Due Diligence 18 The Hoosier Transaction 19 The LILO Test Transactions 20 OBB LILO20 Lease and Sublease23 End of Sublease Term25 SNCB 2 and SNCB 5 Lot 1 LILO Transactions25 Lease and Sublease28 End of Sublease Term 28 The SILO Test Transactions 29 TIWAG29 Lease and Sublease33 End of Sublease Term35 Two Dortmund Transactions35 Lease and Sublease38 End of Sublease39 SNCB SILO39 Grant and Subgrant42 End of Subgrant Term 43 Tax Returns, Notices of Deficiency, and Trial 43 Procedural History48 Trial 53 Opinion 53 Burden of Proof53 Principal Place of Business54 Leveraged Lease Transactions54 Frank Lyon58 LILO and SILO Litigation 77 The Test Transactions 78 Economic Substance79 Objective Inquiry88 Subjective Inquiry89 Substance Over Form91 OBB and SNCB LILO Transactions110 SILO Test Transactions 145 Interest Deductions 147 Original Issue Discount 149 Transaction Expenses 149 Conclusion NOTE: NO FURTHER DISCOUNTS FOR ALREADY REDUCED SALE ITEMS. Keywords: tax court reports, reports of the united states tax court, u.s. tax court reports, united states tax court reports, united states tax court, u.s. tax court, tax court
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Tax administration and procedure
Languages : en
Pages : 696
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